The amount of environmental information that an organization is required by the government to collect and report is enormous and increasing. Prior to 1976, the environmental engineer assigned to the task of collecting and reporting this environmental information merely ensured that the hazardous waste was handled and disposed in compliance with government regulations, without specifying the details of how that information related to chemical use. However, in 1986, the Superfund Amendment and Reauthorization Act (SARA) was added. This law required that industry track and report chemical use through numerous and voluminous reports. The SARA act requires that industry know the amount and location of each chemical used in that industry, as well as the final point of disposition (air emissions, containerized waste, and wastewater discharge, for example). Additional laws, including the 1990 Pollution Prevention Act and the new Clean Air Act, added additional requirements resulting in further increases in the number and volume of required reports.
In the future, this trend toward more detailed reports is expected to continue. It is expected that governmental requirements will increase beyond those dictated by the current laws.
For the environmental engineer at a manufacturing site subject to these laws, obtaining information on chemical use is difficult because a specific chemical is usually not dedicated to a specific product or use. Without direct information, the engineer must prepare reports on chemical use by obtaining information on the chemical to be used, and the specific facility location of the chemical use. They may request information from various sources such as materials handling, chemical operations, facility operations, etc. The information is then used to prepare environmental reports on chemical use for a specified time period, at a specific industrial site. The information may include printouts of computer information, records of raw materials delivered to the site, or records of subcontractors indicating chemicals which were brought and consumed on the site (cleaning, pesticide applications, and stock room issuance for instance). The environmental engineer attempts to compile this information by chemical ingredient using the chemical information from the Material Safety Data Sheet and from the product vendor. Quantities of chemicals purchased are then enumerated by multiplying the amount of the product purchased and used during that timespan by the percent of the product represented by each chemical ingredient. These individual totals are then added up so that the final data enumerates how much of each chemical ingredient was used entotal during that timespan. This data calculated in the above described manner satisfies some of the requirements of the current laws, for example SARA 311/312. Evaluating chemical use via such limited resources inherently introduces a certain degree of potential inaccuracy into report quantities. In addition, some of these reports required by law, (for example, SARA 313 toxic chemical release inventory, air emissions inventories, and pollution prevention) require even more accurate information. These laws require that reports include the ultimate destination of each chemical ingredient. For example, the environmental engineer must provide information on how much of the chemical went into the atmosphere via air emissions, how much was represented in containerized waste and how much was discharged into waste waters. One method of determining this "mass balance" quantity per chemical ingredient is to obtain the evaporation rate of a particular chemical product and to presume that, regardless of the process where the chemical product is used, a specified amount of the chemical ingredient has evaporated into the atmosphere. The accuracy of this mass balance approach has been questioned.
To summarize, most chemical use industries order chemicals, and when these chemicals are delivered to the site they are picked up and used with no further record keeping. Without knowledge on what chemical products are used at what process, the mass balance or chemical use and emissions estimates used to formulate the data for reports such as the SARA 313 Toxic Chemical Release Inventory Report must be based on high level data and on assumptions of chemical dispersion which do not take into account the wide range of process conditions and resulting chemical dispersion opportunities.